Bullying Forum Consultation – A Focus on Bullying and Early School

Leaving Prevention

Submission: Dr. Paul Downes

Director, Educational Disadvantage Centre,

Senior Lecturer in Education (Psychology)

St. Patrick‘s College, Drumcondra 4. What are the key priorities that need to be addressed, including actions to be taken by

the Department of Education and Skills, other government department and agencies and

school communities?

4(a) A bullying prevention and intervention strategic focus as part of a mental

health promotion and early school leaving prevention strategy across health and

education

*More recognition is required in the Department of Health that bullying and early school

leaving prevention are key factors in a mental health strategy for children and young

people –the Health Ministry need to also commit to including the prevention of bullying

and early school leaving within its key outcomes

* The need for emotional supports, including for bullying prevention, is recognised by

2011 European Commission and Council documents on early school leaving prevention

for the EU2020 target and by the Joint Oireachtas Education Committee report on early

school leaving (2010). A strategic focus on mental health and emotional supports for

bullying and early school leaving prevention is largely missing from the DEIS strategy

* The Irish post-primary figure of 5% for suspension, applied to the total population of

332,407 students equates to well over 16,000 students suspended from post-primary

schools in 2005/6 (ERC/NEWB 2010), with figures in June 2012 (NEWB) giving 1,051

suspensions in primary schools 2009/10 and 14,162 in postprimary. Many of these

students, including those manifesting violent and aggressive behaviour, require mental

health/emotional supports through more structured engagements with community mental

health services. Some pupils and students displaying consistently high levels of

aggression and bullying are reacting to deep trauma in their lives that requires a layer of

therapeutic support going beyond the immediate school context.

Swearer et al.'s (2010) review of international research on bullying highlights that studies

have demonstrated that children who are bullied are more likely to avoid school (e.g.,

Kochenderfer & Ladd, 1996; Olweus, 1993) or even leave school early (Fried & Fried,

1996). It is also notable that evidence suggests that the effects of bullying are exacerbated

for those already at risk of early school leaving; Beran (2008) concluded that

preadolescents who are bullied are at some risk for demonstrating poor achievement,

although this risk increases substantially if the child also receives little support from

parents and is already disengaged from school.

Child-centred research in DEIS primary and postprimary schools in Ballyfermot (Downes

2004) and Dublin 8 (Downes & Maunsell 2007) observed an explicit link between

children‘s accounts of being bullied and their nonattendance at school.

The European Commission proposal for a European Council Recommendation on early

school leaving (2011) observes the need for ‗developing anti-violence and anti-bullying

approaches‘.

*There is a clear need for explicit strategic links between the community mental health

teams allocated 35million in the recent budget and primary/secondary schools (and

education services such as home-school liaison, national behavioural support service),

especially for bullying and early school leaving prevention outcomes

*There is a need for formal presence of school completion coordinators and home-school

liaison teachers on these community mental health teams – to focus on a) a joint local

strategic approach between education and health for family support outreach and b) direct

emotional supports for parents and children most in need of emotional/mental health

supports and at risk of school nonattendance and early school leaving

4(b) The need for a systemic focus on bullying prevention and intervention that

includes a school wide level and engagement with families

In a report for the Swedish National Council for Crime Prevention, Ttofi,

Farrington and Baldry's (2008) meta-analysis evaluated 30 bullying intervention studies.

Swearer et al. (2010) observe that 'This meta-analysis was noteworthy because of the

rigorous study selection procedures used (i.e., focus on reducing school bullying,

bullying defined clearly, bullying measured using self-report, studies that included both

experimental and control conditions, inclusion of effect sizes, and sample sizes of

200 or larger). Results indicated that bullying and victimization were reduced by 17% to

23% in experimental schools compared with control schools...Ttofi et al. found that

reductions in bullying were associated with parent training, increased playground

supervision, disciplinary methods (dichotomized as punitive vs. nonpunitive),

home–school communication, classroom rules, classroom management, and use of

training videos'. (p.42). As Swearer et al. (2010) observe, 'There was a dosage effect; the

more elements included in a program, the greater the likelihood of reducing bullying. The

researchers also noted that anti-bullying programs were more efficacious in smaller scale

European studies and less effective in the United States' (p.42).

As noted by Swearer et al. (2010), Vreeman and Carroll (2007) examined the

findings of 26 studies evaluating school-based anti-bullying efforts, distinguishing

between classroom curriculum studies, whole-school/multidisciplinary interventions, and

targeted social and behavioral skill training for bullies and victims. The most promising

results were reported for whole-school anti-bullying efforts, including those to establish

schoolwide rules and consequences for bullying, teacher training, conflict resolution

strategies, and classroom curricula and individual training. Schoolwide programs were

found to be far more effective in reducing bullying and victimization than were

classroom curriculum programs or social skills training strategies.

The need to adopt a systemic approach to bullying prevention as a factor against

early school leaving was also noted in a Canadian context by Lacharite & Marinii(2008):

'In keeping with the contextualizing of bullying as a multifaceted issue, there has been an

increasing concern with the 'health' and 'democratic' deficits associated with the

experience of bullying and victimization' (p.297); there is 'a critical need for multilevel

intervention' (p.303). Downes (2009) highlights the need for continuity between school

and community subsystems with regard to promotion of a positive school climate, as

community level stresses will impact upon school climate unless a holistic approach to

intervention occurs in contexts of social-economic disadvantage.

Swearer et al. (2010) propose a systemic level of strategic intervention:

'the systems directly affecting children and adolescents include families, schools, peer

groups, teacher–student relationships, parent–child relationships, parent–school

relationships, neighborhoods, and cultural expectations.' (p.42). Swearer et al. (2010)

conclude from their international review that: 'The research that has been conducted on

bullying prevention and intervention suggests that anti-bullying initiatives should include

individual, peer, family, school, and community efforts' (p.43). Swearer et al. (2010)

further conclude 'the research suggests that the majority of school-based bullying

prevention programs have had little impact on reducing bullying behavior. Bullying will

be reduced and/or stopped when prevention and intervention programs target the

complexity of individual, peer, school, family, and community contexts in which bullying

unfolds' (p.43). This need for a systemic focus on school-wide, family and community

contexts requires a key strategic focus on developing future multi/interdisciplinary teams

in this area to engage in intervention for behavioural and bullying issues as part of an

early school leaving prevention strategy.

4(c) Need for outreach dimension for family support

Facilitating service linkages may be critical given barriers that many families

face, particularly those that are financially underprivileged (Flisher et al., 1997), in

attempting to obtain needed treatments for their children. Youth who are low-income,

and/or ethnic minority are even less likely to access health care—often related to lack of

insurance or transportation, distance from providers, or stigma attached to seeking mental

health treatment (Dey, Schiller,&Tai, 2004). In the context of implementation of the

international right to the highest attainable standard of health, Hunt & Backman (2008)

refer to the key role of 'outreach programmes for disadvantaged individuals and

communities' (p.11) and observe that 'a State has a core obligation to establish effective

outreach programmes for those living in poverty' (p.12). Community outreach best

practice also means that 'recruitment of health workers must include outreach

programmes to disadvantaged individuals, communities and populations' (Hunt &

Backman 2008, p.17). In a report of the UN Special Rapporteur on the right of everyone

to the highest attainable standard of physical and mental health, Paul Hunt (2006)

observes international good practice as ‗7....Properly trained community health workers

[who]…know their communities‘ health priorities…Inclusive, informed and active

community participation is a vital element of the right to health‘.

As Stephan et al. (2011) observe, School-based health centers (SBHCs) are a

common site for collaborative school-based care in the US context. SBHCs employ a

multidisciplinary team of student-care providers, including registered nurses, nurse

practitioners, physicians, physician assistants, social workers, alcohol and drug

counselors, and other health professionals.19 SBHCs in six states: Colorado, Louisiana,

Michigan, New Jersey, North Carolina, and West Virginia. However, no outreach

dimension to families is described. Stephan et al (2011) conclude that 'In addition to an

increased focus on family engagement, the MHET [Mental health and emotions]

initiative would have benefited from evaluative feedback from families (and other

stakeholders, including students and teachers) on the value and impact of the intervention'

(p.79). A community based team rather than a school-based one offers an improved

pathway into parental engagement, for families especially marginalised from the formal

system and their children at heightened risk of nonattendance at school and early school

leaving. It certainly cannot be assumed that those most in need will access available

services. This requires acknowledgement of the need for an outreach to reach the more

marginalised.

Downes‘ (2011) review for the European Network of Experts on the Social

Aspects of Education and Training (NESET) concludes: International research points to a

clear consensus regarding the strategic directions concerning mental health priority

aspects for multi/interdisciplinary teams, as part of a bullying prevention and early school

leaving strategy. Empirical evidence from quantitative and qualitative sources highlights

the need for interventions for the following priority areas:

a) at the individual child and family level:

emotional support services for students to have someone to confide in, including

therapeutic supports, as a protective factor for their mental health and to foster

motivation and engagement in school and psychological supports in relation to the

effects of bullying and traumatic events

targeted language support services for children's language development, including

systemic work with families

emotional and behavioural support services to work with students displaying

challenging behaviour and alienation from school

outreach strategies in a culturally sensitive manner, to reach families marginalised

from the education system

b) at the school system level:

developing teacher conflict resolution skills and diversity awareness training for

teachers

developing whole school and in-class bullying prevention approaches

developing alternatives to suspension

developing a wider range of language development strategies in class.

International research suggests that community based teams working also onsite in

schools offer a model of good practice to engage with the different systemic levels of

intervention at individual, group/peer, school, family and community levels.

Outcome indicators as part of a strategic direction for such mental health

multi/interdisciplinary teams are:

a) at an individual level

gains in attendance at school

improved behaviour in class

decrease in bullying in class and school

decreased anxiety and depression and improved mental health, including

academic self-efficacy and global self-esteem

increased academic motivation and performance

increased language development

at a family level

increased engagement of previously marginalised families with support services

increased engagement of previously marginalised families with the school

improved communication between child and parents

b) at the school system level

decreased use of suspensions

increased use of alternatives to suspension

improved school and classroom climate

decrease in bullying in class and school

4(d) A language development strategic focus as part of a mental health promotion

and bullying prevention strategy, targeting DEIS schools

*Bullying needs to be viewed as a problem of communication and emotional literacy.

Recognising this, the importance of language support dimensions comes to the fore,

especially for prevention of bullying in contexts of educational disadvantage.

The need for speech and language therapists onsite in schools to engage in

targeted intervention for language development emerges from international research

regarding language impairment as a risk factor for correlates of early school leaving, such

as engagement in disruptive behaviour. Eigsti and Cicchetti (2004) found that preschool

aged children who had experienced maltreatment prior to age 2 exhibited language delays

in vocabulary and language complexity. The mothers of these maltreated children

directed fewer utterances to their children and produced a smaller number of overall

utterances compared to mothers of nonmaltreated children, with a significant association

between maternal utterances and child language variables. Rates of language impairment

reach 24% to 65% in samples of children identified as exhibiting disruptive behaviors

(Benasich, Curtiss, & Tallal, 1993),and 59% to 80% of preschool- and school-age

children identified as exhibiting disruptive behaviors also exhibit language delays

(Beitchman, Nair, Clegg, Ferguson, & Patel, 1996; Brinton & Fujiki, 1993; Stevenson,

Richman, & Graham, 1985).

*There is a need to move many speech and language therapists currently based in clinics

to spending more time on school sites, so that they can rotate across schools and work

also with teachers‘ language/literacy teaching strategies and parents‘ language teaching

skills

* Children frequently miss visits in clinics and are much more available for engagement

with speech and language therapists when at school

*The issue of a language development dimension is not simply to target those at the level

of a clinical speech and language disorder. There is a key role for speech and language

therapists in providing system level supports a) to teachers, b) parents, as well as c)

working with individual children. It is acknowledged already somewhat in DEIS and the

NESF report (2009) on child literacy and social inclusion.

*See also Question 6 re: an integrated language/emotional literacy promotion and

bullying prevention approach

6. Are there any exemplars of effective practice, drawn from Irish or an international

context, that you consider could be usefully introduced in our schools?

*This intervention treats bullying as a problem of communication and emotional literacy

Title The 4Rs

Program:

Reading, Writing,

Respect,

and Resolution

Country US Timescale

and date

2009-2011,

3 years

Target

population

Universal though

with a focus on

Children at risk

of trauma, lower

social

competence and

externalizing

problems, and

with lower

language and

literacy skills

Level of

intervention

Systemic at the

level of the

school (students,

teachers)

Targeting also

the skills of the

teacher for

social-emotional

learning and

language

development

1. Description

Description and

justification of the

intervention

Aber et al. (2011):The 4Rs Program: Reading, Writing, Respect,

and Resolution

The 4Rs Program is a universal, school-based intervention that

integrates Social and Emotional Learning into the language arts

curriculum for kindergarten through Grade 5. Evolving from the

previous stand-alone conflict resolution program that was RCCP, the

4Rs uses high-quality children‘s literature as a springboard for helping

students gain skills and understanding in several areas including

handling anger, listening, cooperation, assertiveness, and

negotiation. The 4Rs represents the most recent stage in the

evolution of work promoting Social and Emotional Learning in NYC

public schools by

ESR, now called the Morningside Center for Teaching Social

Responsibility (MCTSR). The 4Rs program has two primary

components: (a) a comprehensive seven-unit, 21-lesson, literacy-

based curriculum in conflict resolution and social–emotional

learning for K to Grade 5; and (b) intensive professional

development and training in 4Rs for teachers. Each unit is organized

around a specific grade-appropriate children‘s book and

begins with a comprehensive book reading and discussion, ensuring

students understand the primary themes of the story and

allowing them to connect the themes to their own lives. This is

followed by three to five social–emotional learning lessons.

The curriculum provided to teachers includes a standardized,

grade-specific teaching guide. Intensive professional development

for teachers in the 4Rs curriculum consists of a 25-hr introductory

training course, followed by ongoing classroom

coaching throughout the year by a 4Rs staff developer (an experienced

teacher coach, master facilitator of social and emotional

learning activities in the classroom, and expert in the 4Rs curriculum)

to support teachers in teaching the 4Rs curriculum'.(p.414)

Aber, L., Brown, JL, Jones, SM., Berg, J. & Torrente, C. (2011).

School-based strategies to prevent violence, trauma,

and psychopathology: The challenges of going to scale. Development

and Psychopathology, 23 (2011), 411–421

Design and purpose of

the evaluation.

Seek to explore school-based universal preventive interventions

as a frontier in translational research on trauma and

trauma-related problems in development

Aber et al (2011) 'the context as mental health prevention and

promotion meets education reform' (p.411)

At each wave, teachers were consented and

completed questionnaires rating the language and literacy skills,

aswell as social competence and externalizing problems, of each

consented child in their class. Teachers also completed questions

rating the climate of their school and their own social and emotional

skills and behaviors, including their professional background

and development, their beliefs about the importance of

social–emotional learning in school, their classroom management

strategies and styles, and their experiences of stress and

burnout. Consented children also completed questionnaires rating

their aggressive and pro-social cognitions, and their internalizing

symptoms. Children‘s yearly scaled scores on the New

York State standardized assessments of math and reading

achievement and attendance rates were obtained from the

NYC Department of Education.

2. Evidence

Intended outcomes

Gains in students':

attendance rates

social-emotional mental health

social competence and peer network communication

reading achievement

maths achievement

Reduction in students':

depression

aggressive behaviour,

cognitive attitudes regarding aggression, i.e., self-reported

hostile attributional biases

Gains in quality of teachers':

social–emotional learning in school

classroom management strategies and styles, including conflict

resolution skills

Actual outcomes

After 2 years of exposure to 4Rs, in addition to continued

positive changes in children‘s self-reported hostile attributional

biases and depression, positive changes were also found in

children‘s reports of aggressive interpersonal negotiation strategies

(i.e., their tendency to select aggressive responses in conflict

situations), and teacher reports of children‘s attention-deficit/

hyperactivity disorder (ADHD), social competence, and

aggressive behavior

Aber et al., (2011) 'Similarly, there were both

continued and expanded positive impacts of the program for

children rated by their classroom teacher as highest in initial

behavioral risk. Specifically, compared to similarly identified

children in control schools, children in 4Rs schools at highest

initial behavioral risk continued to show the most substantial

gains in teacher reports of academic skills, but also in both

standardized reading and math achievement test scores' (p.415)

Aber et al., (2011) 'these findings indicate both short-term and

longer term impacts of the 4Rs program both for the general

population of students as well as for those students at highest

behavioral risk as perceived by their teachers.' (p.415)

at the child level, initial findings after 1 year of exposure to the 4Rs

Program were modest, indicating that children in 4Rs schools had lower

average levels of self-reported hostile attributional biases and

depression compared to children in control schools. In addition, for

those children identified by teachers at baseline at highest behavioral

risk, there were positive intervention impacts on children‘s

self-reports of aggressive fantasies, teacher reports of

academic skills, attendance records, and standardized reading

achievement (Jones, Brown, Hoglund, & Aber, 2010).Jones, S. M.,

Brown, J. L., Hoglund,W. L. G., & Aber, J. L. (2010). Impacts

of an integrated school-based social–emotional learning and literacy

intervention on third-grade social–emotional and academic outcomes.

Journal of Consulting and Clinical Psychology, 78, 829–842.

at the classroom level, after

1 year of exposure to the program, 4Rs school classrooms

were rated by trained, independent observers as having higher

quality interactions on average compared to control school

classrooms, suggesting that 4Rs can improve the quality of

both classroom instructional and emotional support provided

by teachers (Brown, Jones, LaRusso, & Aber, 2010).

Brown, J. L., Jones, S. M., LaRusso, M. D., & Aber, J. L. (2010).

Improving

classroom quality: Teacher influences and experimental impacts of the

4Rs Program. Journal of Educational Psychology, 102, 153–167.

Type of evaluation/data

Quantitative. Control Group Design. Longitudinal, school-randomized

trial to test the impacts of the 4Rs program on classroom.

and teacher processes and outcomes as well as on children‘s social–

emotional and academic development. Eighteen New York City public

schools were pairwise matched on key school-level demographic

characteristics. One school from each pair was

randomly assigned to receive schoolwide intervention in 4Rs

over three consecutive school years and the other school to a

―business as usual‖ control group

Evaluating the data

Rigorous, control group design. Recent publication of findings in

international journals, Journal of Consulting and Clinical Psychology

(2010), Journal of Educational Psychology (2010), Development and

Psychopathology (2011).

A challenge for replication in other cultural contexts would be to ensure

that the team members working with children and teachers on systemic

change would themselves have sufficient training background. This

universal prevention approach adopted here offers much potential for

those at heightened risk of bullying and early school leaving, especially

in conjunction with selected and indicated prevention approaches that

include family level interventions.

3. Conclusions

Ways of working

Aber et al., (2011):

* 4Rs promotes change processes at multiple levels (e.g., individuals,

their interactions, and proximal settings including their classroom

and school environments

* 4Rs was designed based on the idea that improving functioning

in one domain (e.g., interpersonal interactions) influences functioning

in other domains (e.g., academic engagement and attention

* 4Rs is designed to promote change at multiple levels in

multiple domains over time as dynamic systems

* impacts associated with exposure to the 4Rs Program were expected

to be cumulative, resulting initially in small to modest changes in

domains of functioning most proximal to the intervention and

within some levels but with longer and sustained program exposure,

expanding to more distal domains of functioning and outcomes

(e.g., from reductions in hostile attribution bias to reductions

in aggression and increases in social competence) across

multiple levels (e.g., from changes in children‘s skills to changes

in the structure of their peer networks). (p.414)

Policy

recommendations made

by the evaluation.

Aber et al., (2011)

'Our findings to date contribute to the growing evidence

that primary prevention strategies designed to address children‘s

social–emotional as well as academic learning can

be effectively integrated and become part of standard practice

in classrooms and schools. Further, our findings suggest that

doing so can significantly improve the quality of key aspects

of children‘s social settings such as the quality of their classroom

interactions with teachers and peers, and reduce the risk

of aggressive behavior, depression, and ADHD, three of the

most ubiquitous forms of psychopathology associated with

exposure to trauma and violence.' (p.417)

* The major importance of having a system wide focus on the school

environment rather than an exclusively individual focus on

interventions for the child

General comments

The 4Rs Program has led to modest positive impacts on both

classrooms and children after 1 year that appear to cascade to more

impacts in other domains of children‘s development after 2 years.

An implication of the major increase in gains after the second

year is that systemic interventions bringing change to children's

behaviour and emotions, as well as school reform, requires

sufficient time for impact to be assessed. This requires at least a

3 year period, one for design and recruiting, and the other two

for implementation and then ideally a 4th

year for evaluation of

outcomes.

Combined with sufficient period of time there is a need for

interventions to have sufficient intensity of time for a given

element, to have impact

A combination of mental health prevention/intervention and

academic outcomes focus

Located exclusively in New York, US context

5. Are there any practical steps that can be taken in the short term to improve how

schools approach and tackle bullying?

Steps for further progress recommended in Downes, Maunsell & Ivers (2006) based on

their survey of DEIS primary schools in the Blanchardstown area:

The extreme variation in levels of bullying across 6th

classes within a school suggests

that individual teachers are having significant success with SPHE and preventive

approaches to bullying. However, this success is not being translated fully across all

classes within a school. It would seem that while a whole school approach with

regard to bullying may be having some impact, further development of a co-ordinated

within school anti-bullying strategy may be needed. This would include more

dissemination within the schools and across schools of strategies that are working

well for some teachers with regard to prevention and elimination of bullying.

To facilitate this dissemination of good practice strategies for prevention and

elimination of bullying within the school, it is recommended that a staff member

coordinate such a dissemination strategy and act as a support/mentor for other

teachers in the school. While this staff member would liaise with the school principal

in implementing the whole school anti-bullying policy, (s) he would also serve as an

intermediary between the class teacher and the principal. The class teacher may be

more likely to approach another colleague – in this role as coordinator - for informal

advice on intervention for bullying. For example, at secondary level, Blakestown

Community School have developed the good practice of an ‗anti-bullying

committee‘, a ‗cool-school committee‘ for bullying.

The key role of the class teacher regarding within-class bullying was observed in a

study in a primary school in Ballyfermot (Downes 2004a) where the class teacher

employed strategies such as an anonymous problem box, role play and circle time to

eliminate a bullying problem that had existed in the class the previous year when

there were a number of substitute teachers.

A whole school approach needs to utilise a) bullying poems, b) a suggestion box for

problems without mentioning names as part of circle time for SPHE. The new revised

primary school curriculum (1999) offers a wide range of subjects through which

bullying can be prevented as an integrated theme – across English (bullying poems),

drama, religion, sphe, empathy in history (Downes 2009)

Based on pupil accounts, three domains of bullying need to be regularly examined:

in-class, in the yard (between classes and years) and after school (Downes 2004a)

Visible public antibullying statements on the walls of the secondary school, such as in

this secondary school in Dublin 8 (Downes & Maunsell 2007): ―It‘s become a part of

their routine to take his money and make him scream to twist his arm and bash his

head, if you tell sir that‘s it! You‘re dead! However this is not the case!‖

There is a need for anonymous school surveys on bullying given the finding from

international and Irish research that teachers consistently underestimate levels of

bullying in their class and in the school (Tattum 1997; Downes 2004).

*A range of Irish research in DEIS post-primary schools and international research (see

Downes 2011a for a review) points to the direct role of relations with teachers as

impacting upon students‘ decisions to leave school early; much of this is preventable

through adequate preparation of teachers‘ conflict resolution and diversity training skills.

There is a need to continue the movement from an authoritarian to an authoritative school

culture/climate, for example, through working with teachers on teacher/student

interaction and conflict resolution on the new 2 year postprimary H.Dip In illustrative

accounts of student voices in regarding authoritarian teaching, Downes & Maunsell

(2007), it was stated, “The only bullying problem is the teacher”, ―If you make a mistake

she starts roaring at you”,“She made X cry”etc

* Make teacher conflict resolution skills a compulsory element of all post-primary H. Dip

courses as part of the extension of this preparation to 2 years. This is part of a wider

bullying prevention strategy that focuses on promotion of healthy communication in the

culture of a school, communication and conflict resolution skills that are to be modelled

by teachers for students

Appendix 1: Submission Form

CONSULTATION ON TACKLING BULLYING IN SCHOOLS

Respondent’s Details Name Dr. Paul Downes

Position (if applicable) Director, EDC, Senior Lecturer in

Education (Psychology)

Organisation (if applicable) Educational Disadvantage

Centre

Address St. Patrick’s College, Drumcondra

Telephone (01) 8842156

Email address paul.downes@spd.dcu.ie

Date June 20, 2012

Is this response a personal view or is it made on behalf of an organisation?

Personal [ ] On behalf of an organisation [YES, EDC ]

Submissions may be in English or Irish.

Please note that submissions received may be made available from the DES website.

Information in relation to this submission may be made available to any person who

makes a request under the Freedom of Information Acts 1997 and 2003.

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